DEC292016_07D2101Decided 2016-12-29I-129

A small floral design company's H-1B petition for a community relations coordinator was dismissed because the…

Dismissed Useful for: avoid these mistakes
H-1BField: florist / floral design company seeking community relations coordinator
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to demonstrate that the community relations coordinator position qualifies as a specialty occupation under any of the four regulatory criteria. The petitioner's claimed degree requirement (business administration or related field) was too generalized to establish the position as a specialty occupation.

In plain English

A three-employee florist company sought H-1B classification for a community relations coordinator who would work with Bulgarian floral shops. The Vermont Service Center denied the petition, and the AAO affirmed on appeal. The AAO found the position failed all four specialty occupation criteria because the petitioner only claimed a general-purpose business administration degree was required, which is legally insufficient. The DOL Handbook confirmed that public relations specialists can enter the field with degrees in several unrelated disciplines, and the petitioner's Level I wage designation further undermined claims of complexity. An expert opinion was discounted because it did not address the wage level or distinguish the position from ordinary public relations roles.

What worked & what failed

What failed: The petitioner's claimed degree requirement of 'business administration, marketing, international business, or a related field' was too broad and generalized to establish a specialty occupation — courts and USCIS require a specific degree directly tied to the position's duties. The expert opinion letter was discounted because it failed to address the Level I wage designation and did not distinguish the position from ordinary public relations jobs described in the DOL Handbook. The petitioner also inconsistently described the minimum education requirement across its submissions, undermining its credibility.

Takeaway: H-1B petitioners must identify a single, specific degree field that is directly and closely tied to the actual job duties — a general business or multi-discipline degree requirement will defeat the petition. Petitioners should also ensure their LCA wage level is consistent with claims of job complexity, as a Level I designation undercuts arguments that the position is uniquely specialized.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating H-1B criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The petitioner's claimed degree requirement of 'business administration, marketing, international business, or a related field' was too broad and generalized to establish a specialty occupation — courts and USCIS require a specific degree directly tied to the position's duties
  • The expert opinion letter was discounted because it failed to address the Level I wage designation and did not distinguish the position from ordinary public relations jobs described in the DOL Handbook
  • The petitioner also inconsistently described the minimum education requirement across its submissions, undermining its credibility.
Find more H-1B cases with similar evidence patterns →
Where the evidence fell short

Expert opinion from a university professor/department chair opining that the position requires a bachelor's degree in business administration, marketing, or international business — rejected because it did not address the Level I wage designation, did not distinguish the duties from the Handbook's description of public relations specialists, and was inconsistent with other record evidence

O*NET OnLine Summary Report for Public Relations Specialists — found unhelpful because O*NET job zone designations do not specify the field of study required for a degree

Petitioner's claim that the position requires a bachelor's degree in business administration, marketing, or international business — rejected as too generalized and inconsistently stated across submissions

List of coursework in statistics, economics, accounting, management, business law, MIS, public relations, marketing, marketing research, international marketing, international business, strategic management, and business communications — insufficient without showing an established curriculum leading to a degree in a specific specialty is required

How the case moved

Completed

I-129 filed

Community relations coordinator for a small floral design company, handling public relations, vendor relationships, and bilingual web content for Bulgarian floral shops

Completed

Vermont Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2016-12-29

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to demonstrate that the community relations coordinator position qualifies as a specialty occupation under any of the four regulatory criteria. The petitioner's claimed degree requirement (business administration or related field) was too generalized to establish the position as a specialty occupation.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

Find this useful? A coffee helps keep Case Reviewer free and ad-free.

Buy me a coffee
Authorities the office relied on
8 C.F.R. § 214.2(h)(4)(ii)8 C.F.R. § 214.2(h)(4)(iii)(A)8 C.F.R. § 214.2(h)(4)(iii)(A)(1)8 C.F.R. § 214.2(h)(4)(iii)(A)(2)8 C.F.R. § 214.2(h)(4)(iii)(A)(3)8 C.F.R. § 214.2(h)(4)(iii)(A)(4)
Royal SiamA general-purpose bachelor's degree such as business administration, without more, does not justify a finding that a position qualifies as a specialty occupation; the degree requirement must relate directly to the duties of the position
DefensorThe H-1B degree requirement means a degree in a specific specialty directly related to the proposed position
Michael HertzA degree requirement with a generalized title such as business administration, without further specification, does not establish a position as a specialty occupation
Simeio SolutionsThe petitioner must submit a certified LCA demonstrating it will pay the H-1B worker the higher of the prevailing or actual wage
Caron Int'lExpert opinion statements may be used as advisory, but where an opinion is not in accord with other information or is questionable, USCIS is not required to accept or may give it less weight
ShantiFactors for determining common degree requirement include whether the industry's professional association requires a degree and whether firms routinely employ and recruit only degreed individuals
Tapis Int'lA general business degree requirement without more does not establish a specialty occupation
Hird/BlakerIndustry-wide degree requirement can be established by letters or affidavits showing firms routinely employ and recruit only degreed individuals
OtiendeThe burden is on the petitioner to show eligibility for the immigration benefit sought